If a university has several campuses and/or off-site laboratories with different EPA ID numbers, would they all have to opt into Subpart K?
No. If an eligible academic entity has several campuses or off-site laboratories with different EPA ID numbers, and one site chooses to opt into Subpart K, the laboratories at the other sites are not required to opt into Subpart K. The decision to opt into Subpart K is made on a site-by-site (or EPA ID number-by-EPA ID Number) basis (see 40 CFR 262.203). However, in order to promote consistency in the management of laboratory waste within an institution, EPA encourages eligible academic entities to opt in for all its sites.